Managing the Competent Authority Process for U.S.-Based Multinational Enterpriseshttp://www.lexisnexis.com/legalnewsroom/tax-law/b/stateandlocaltaxation/archive/2013/02/13/managing-the-competent-authority-process-for-u-s-based-multinational-enterprises.aspxby Barry Shott, Richard Barrett and Elizabeth Sweigart *
Under pressure to close revenue gaps and to address perceived aggressive tax positions related to the pricing of cross-border transactions, both the U.S. and foreign tax authorities are imposingen-US6.x Production